Abstract

Although both France and the United States take pride in the secularism of their legal systems and claim historical primacy when it comes to establishing a human rights regime based on secular laws, their constitutional separation of Church and State was achieved through very different historical circumstances. By comparing the French and US approaches to republicanism and secularism, this article argues that French history is a prime example of the controlling tendency of European nation-states over religion—and that this is precisely what distinguishes it from the United States. The contribution also shows that the connection between laïcité and France’s imperialism was intimate, and that this represents a second crucial difference between the French and the American conceptions of secularism.

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